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20121215
20121215
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in which market participants operate with some local banks in asia, europe and south america signally to u.s. financial institutions they will have to start treating to avoid cftc swap dealer registrations. approach may also encourage foreign break theaters to be similarly expansive as they crossed the regulatory reform machines. second, the cftc's definition of u.s. persons that dictates registration and application of title vii requirements is overly broad and at times they hurt as a result, market participants do not know whether they or their counterparties are or are not u.s. persons and cannot make informed business planes. in addition, the breadth of the definition makes it nearly certain that some market participants will be the u.s. person for the purpose of u.s. regulation and media person, causing unnecessary overlap and potential regulation. third, regarding sequencing, the cftc is chosen to finalize the title vii rules and require compliance with them before specifying. as a result, market participants be significant uncertainty as to oppose me apply. in contrast, the sec reco
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